As the cellular industry continues to expand, Voice over Wi-Fi (VoWiFi) is gaining attention as an important application. In this application, a cellular user has a dual mode handset that supports traditional cellular service and Wi-Fi access. When the cellular user roams into an area that has Wi-Fi coverage, the user may receive and make phone calls using Wi-Fi as the access, rather than traditional cellular. To transition between the cellular network and the Wi-Fi network, a handoff occurs between the networks. A handoff may present problems for the user, such as a call being disconnected, and problems for the industry, such as using expensive techniques to hand off a call between networks.